Author: Mark Horwitz


The Department of Justice announced that it obtained an order authorizing the Internal Revenue Service to serve John Doe summonses to obtain records of U.S. taxpayers who have offshore accounts established by Sovereign Management & Legal LTD (SML), a Panamanian entity. This is part of the continuing effort of the IRS to discover U.S. citizens and residents with undisclosed offshore accounts. It is the government’s belief that debit cards issued by offshore banks are a means by which U.S. taxpayers gain access to offshore accounts in a secretive manner.   The IRS uses a John Doe summons to obtain information about possible violations of internal revenue laws by U.S. citizens and residents whose identities are not known. SML has no offices in the United States according to its website, but, apparently, the government believes that it can obtain records by subpoenaing an individual whom it believes has control over the offshore business. When the government obtains records, it can then prosecute the individuals who failed to properly report the offshore accounts and the income earned on those accounts.   The government obtained an order from the U.S. District Court in Bozeman, Montana authorizing a John Doe summons to be served upon Mr. Michael Behr of Bozeman, Montana. The John Doe summons seeks information about U.S. taxpayers who may hold offshore accounts during the years 2005 to 2016, established by SML....

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Filing Federal Income Tax Returns

It is time to think about filing your US income tax return and paying the income tax that might be due. The failure to timely file the return can have significant civil as well as criminal penalties. Civil penalties for not filing tax returns are related to the amount of unpaid tax. If a person files late and pays the taxes late, there are two separate civil penalties. First, for each month that the tax return is late a penalty of 5% of the unpaid tax is imposed. Thereafter, an additional 5% is added every month to a maximum...

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